SNAP Stakeholder Workshop: 

Fire Protection Sector

December 2, 2015
Welcome and Introductions

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Climate Action Plan: HFCs

 Continue international diplomacy

 Lead negotiations under the Montreal Protocol to phase down HFCs

 Global phase down could reduce over 90 gigatons of CO2eq by 

2050, equal to roughly two years worth of current global GHG emissions 

 Work with partners in the Climate and Clean Air Coalition to Reduce ShortLived Climate Pollutants to promote climate-friendly alternatives to highGWP HFCs, address technical standards, and reduce emissions from HFC use 

 Address HFCs through domestic actions

 Use existing Clean Air Act authority of Significant New Alternatives Policy 

(SNAP) Program to approve climate-friendly chemicals, prohibit some uses of 

most harmful

• Provide federal leadership by purchasing cleaner 

alternatives to HFCs whenever feasible and by 

transitioning to equipment using safe, more 

sustainable alternatives

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Scope of Meeting

 Background 

 Significant New Alternatives Policy (SNAP) Program 

 Overview of Recent Actions & Future Considerations 

 Alternatives for Fire Protection Sector 

 Discussion 

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• Acceptable - those that reduce overall risk to human health & environment

• Acceptable with use restrictions - if needed to ensure safe use

• Unacceptable

Evaluates alternatives & lists alternatives as:

• Aerosols; Foams; Refrigeration and A/C; Solvents; Fire 

Suppression; Adhesives, Coatings, Inks, etc.

Sectors include:

• Ozone-Depletion Potential

• Global Warming Potential

• Flammability

• Toxicity

Considers: 

• Local Air Quality

• Ecosystem Effects

• Occupational & Consumer 

Health/Safety 5
SNAP Actions

2014-2015

 Issued two acceptability 

notices adding alternatives

 Issued new rule adding 

five low-GWP flammable 

refrigerants with use 

conditions 

 Published Status Change 

Rule prohibiting certain 

HFCs in certain end-uses

 HFC Emissions Avoided: 54-

64 MMTCO2eq in 2025

Near term changes can provide 

both near and long term 

benefits

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July 2015: Change of Status Rule 

• HFC-125 - January 2016

• HFC-227ea & blends - July 20, 2016

• HFC-134a - July 20, 2016/January 1, 2018

Aerosols

• HFC-134a in New Light-Duty Systems - MY 2021

• HCFC & HFC Containing Blends in New Light-Duty 

Systems - MY 2017

Motor Vehicle Air 

Conditioning

• New Supermarket Systems - January 2017

• New Remote Condensing Units - January 2018

• New Vending Machines - January 2019

• New Stand-Alone Units (small medium-temp, large 

medium-temp, low-temp)- January 2019/January 2020

• Retrofitted Retail Food Refrig Equipment and Vending 

Machines - July 20, 2016

Retail Food Refrigeration 

& Vending Machines

• All End-Uses, Except Rigid PU Spray Foam-Various dates 

between January 2017-January 2021

Foams
Some Key Principles Guiding Our Thinking

 SNAP rules will continue to consider individual end-uses

 No across the board GWP cut offs 

 No prohibition on HFCs as a whole, or in any one sector

 New HFCs or HFC blends may be listed if risk not greater 

than other available substitutes 

 Recognition that timing is a critical dimension and that each 

end use has unique considerations 

 Status change actions will be issued through notice and 

comment rulemaking

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September 11 

Stakeholder Meeting

 EPA considering proposed rule that could include:

 Listing acceptable alternatives with use conditions

 Refrigeration & air conditioning end-uses for flammable refrigerants; Fire 

suppression: e.g., streaming agent for aviation 

 Listing of unacceptable alternatives

 Certain HC and HC blends for stationary AC retrofits and MVAC systems 

 Change of listing status from acceptable to unacceptable

 EPA considering later transition dates than in July 20th final rule

 End-uses based on stakeholder comments, EPA analysis

 Refrigeration and A/C

 Rigid PU spray foam

 Fire suppression: e.g., PFCs, SF6, HFC-23

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Next Steps

 Continue to expand SNAP acceptable list

 Continue to work with stakeholders

 E.g., Food Cold Chain Workshop in Montreal (held November 21st)

 Sector workshops and Stakeholder meetings 

 Develop next SNAP Notice for acceptable listings

 Develop next SNAP Rule to include alternatives that are:

 Acceptable with use conditions

 Unacceptable

 Change of status 

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Total Flooding System Applications

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Commercial 

(including 

maritime)

Industrial Aviation Military

• Telecommunication facilities

• Computer 

rooms

• Data processing 

centers

• Maritime

• Museums

• Libraries

• Hospitals

• Medical 

facilities

• Clean rooms

• Petrochemical 

facilities

• Production 

lines

• Grain elevators

• Engine nacelles

• APUs

• Cargo 

compartments

• Aircraft lavatory 

trash receptacles

• Crew spaces of 

armored 

vehicles

• Aviation 

engine 

nacelles and 

dry bays

• Shipboard 

machinery 

spaces
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Total Flooding Alternatives GWP

HCFCs and HCFC Blends 609 - 1,546

HFCs and HFC Blends 1,598 – 14,800

PFCs 8,830 – 8,860

FK-5-1-12 (NovecTM 1230) <1

CF3I 0.4

PBr3 0

Inert Gas Blends 0

Inert Gas Generators <1

Carbon Dioxide 1

Water 0

Water Mist Systems 0

Powdered Aerosols 0
Streaming Agent Applications

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Commercial

(including maritime) Industrial Aviation/Aerospace Military

• Cable trays

• Computer rooms

• Data centers

• Telecommunications 

facilities

• Electronic 

compartments

• Ship control rooms

• Transmission facilities

• Utility vaults

• Art galleries

• Banking facilities

• Libraries

• Retail and wholesale 

facilities

• Warehouses

• Process control 

facilities

• Motor control 

rooms

• Manufacturing 

plants

• Clean rooms

• Oil and gas 

facilities

• Conventional and 

nuclear power 

plants

• Hazardous 

materials storage 

areas 

• Onboard aircraft

• Control towers

• Aircraft flight 

lines

• Aircraft ramps

• Aircraft rescue 

and firefighting 

vehicles

• Spacecraft 

facilities

• Electronics 

facilities

• Ship control 

rooms

• Training

• Aircraft flight 

lines
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Streaming Agent Alternatives GWP

HCFC Blend B 222

HFCs 3,220 - 9,810

PFC 9,300

FK-5-1-12 <1

FK-6-1-14 (C7 Fluoroketone) 1

CF3I 0.4

H Galden HFPEs 2,790 – 6,230

Dry Chemicals 0

Carbon Dioxide 1

Water 0
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 EPA considering a proposed rule that may consider:

 Listing of 2-BTP as acceptable in certain applications

 Change of listing status from acceptable to unacceptable for:

 PFCs (C3F8 and C4F10) in fire suppression total flooding uses

 PFC (C6F14) in fire suppression streaming uses

 Request for comments and updated information on total flooding 

uses of SF6 and HFC-23

 Comments on July SNAP final rule, recent petitions suggested 

EPA also consider fire suppression applications

 Seeking stakeholder input pre-proposal given interest in 

applications
Open Dialogue –

Questions and Answers
Discussion Questions

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 What specific end-uses and applications need additional low-GWP 

alternatives? 

 Are additional submissions anticipated for fire protection applications 

(e.g., new chemicals, new blends, existing chemicals for new applications, 

new processes or technologies)?

 Under SNAP, a potential substitute is often submitted for review for more 

than one use in a particular sector. EPA reviews substitutes on an end-use 

by end-use (or end-use category) basis. Is it helpful for EPA to move 

forward with listings in particular end-uses where we have made a 

determination recognizing we may still be reviewing other end-uses?